Submission to Preferred Project Report for Proposed
Mixed Use Redevelopment
by Leichhardt Council
Balmain Leagues Club Precinct
This submission has been prepared
with technical input from the following:
Leichhardt Council
Councillors and Staff
Urban Planning
Stuart Harding
Rachel Mitchell
Willana Associates P/L
Willana Associates P/L
Economic Assessment
Peter Leyshon
Leyshon Consulting P/L
Urban Design and Architecture
Philip Thalis
Hill Thalis
Peter Smith
Smith Tzannes
Kerry Clare
ClareDesign
Transport and Traffic
Ken Welsh
Leichhardt Council
Andrew Hulse
ARUP
Montages
John Zhang
Australian Illustration & Modelling Co. P/L
For further advice, please contact
Stuart Harding
Director
Willana Associates Pty Ltd
PO Box 170
Randwick NSW 2031
p: (02) 9399 6500
f: (02) 9399 6555
www.willana.com.au
Job No: 9071af
December 2012
© Willana Associates Pty Ltd 2012
ABN 93 868692799
table of contents
1
Introduction ____________________________________________________ 1
2
The Strategic Context ____________________________________________ 4
2.1
2.2
3
Applicant’s Justification _______________________________________ 4
Precedent Cases __________________________________________ 12
Traffic and Parking ______________________________________________ 16
3.2
Arup traffic and parking assessment ____________________________ 18
4
Retail Impacts __________________________________________________ 21
5
Urban Design __________________________________________________ 23
5.1
5.2
5.3
5.4
NSW Government’s Metropolitan Strategy _______________________ 23
The Department of Planning + Infrastructure Schedule 1 - Fundamental
Issues to be Addressed _____________________________________ 25
The Department of Planning + Infrastructure Schedule 2 - Other Key
Issues to be Addressed _____________________________________ 26
DRP Conclusion ___________________________________________ 31
6
Voluntary Planning Agreement ____________________________________ 32
7
Conclusion ____________________________________________________ 34
appendices
Appendix A – Montages prepared by Australian Illustration & Modelling Co. P/L
Balmain Leagues Club Precinct - PPR: Leichhardt Council’s Submission
1 Introduction
This submission provides comment from Leichhardt Council to the NSW Department of
Planning and Infrastructure (DoPI) on the Preferred Project Report (PPR) for major project
MP11_0015. The project is for the construction of a Mixed Use Commercial, Retail and
Residential Development at the site of the former Balmain Leagues Club and adjoining lands
on Victoria Road, Rozelle.
This submission should be read in-conjunction with Council’s submission dated June 2012 in
relation to the Environmental Assessment of the project. Matters not addressed in this
current submission but raised in Council’s previous submission, remain relevant concerns.
Council maintains its’ position, that the proponent has not provided adequate justification for
a “landmark” building at the site. In essence, the proposal remains an overdevelopment of
the site. The site cannot accommodate such an intensive form of development without
adverse amenity impacts on the locality.
The original Environmental Assessment (EA) report submitted by the proponent’s ignored
the considered hierarchy of centres as contemplated in the strategic planning framework for
Sydney. Although the development is called “Rozelle Village”, in the proponent’s justification
for the development in the April 2012 EA, there is no acknowledgement that the site is
located within a “small village” as identified under the Inner West Subregion – draft
Subregional Strategy.
In Council’s submission of June 2012, the established framework within which the
application should be assessed was highlighted. Council’s submission carefully reviewed
high level planning frameworks that are used to guide future planning outcomes for site. The
submission identified that Rozelle had been consistently recognised in the relevant State,
Metropolitan, Subregional and Local policy levels as an area that could only support “small
village” outcomes.
Leichhardt Council constituted a Design Review Panel (Panel) to advise on the design
aspects of the amended Preferred Project. The Panel has reviewed the amended application
in relation to SEPP 65, which includes ten Design Quality Principles and the requirements
for a Qualified Designer (a Registered Architect) to provided Design Verification Statements
throughout the design, documentation and construction phases of the project.
The Panel has concluded that the proposal continues to be an ill-conceived ambit claim
unrelated to the Sydney Metropolitan Strategy, the DCP or the requirements of SEPP 65.
The Panel considers this proposal would have large and long lasting detrimental impacts on
Rozelle. The Panel can find no positive outcomes for the residents and businesses within
the local area that would arise due to this proposal.
The DoPI, in their letter to the proponent, dated 8 August 2012, concurred with the planning
framework established in Council’s original submission. The DoPI’s letter includes: The
Department is of the view that the exhibited proposal is unacceptable for the site, particularly
in relation to height and floor space…It is emphasised that you will need to give urgent
consideration to the height of the proposal and to provide solid justification for the amended
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
1
height in the context of the site’s location. The DoPI detailed a number of fundamental
planning and environmental amenity issues that needed to be resolved, including:
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Building height and scale
Density
Traffic and parking
Retail impacts
Urban design.
The proposal remains a significant development demonstrated by the fact that it still
includes:
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A podium of 2 to 3 storeys.
Towers with a height of 24 storeys including podium.
A floor space of 43,500m² and a floor space ratio of 5.3:1.
Retail distributed over 3 levels.
On-site parking for 509 spaces.
This submission identifies Council’s concerns with the amended proposal presented in the
Preferred Project Report (PPR) dated October 2012 including:
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The justification for the proposal in the context of the Strategic Planning Policy
Framework guiding the development of the site.
Architectural, Building, Urban Design Impacts and Built Form.
Traffic and Parking.
Retail Impact.
Development Contributions.
The proponent is essentially seeking support for the Preferred Project on the premises that
the proposal will:
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Increase housing supply in the local government area (LGA)
Increase employment opportunities in the locality
Is an opportunity to provide a “gateway” to Rozelle.
Council asserts that a development that is designed to be compatible with the context of the
site’s location, that is a “small village”, can also:
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Increase housing supply in the LGA
Increase employment opportunities in the locality
Be designed as a gateway to Rozelle
However, the issue which the proponent has not addressed in the PPR, is defining the
tipping point in regards to the scale of the development, in order to achieve the above
outcomes but with acceptable impacts on the community and future residents. In contrast,
the scale of the Preferred Project, results in impacts that are no longer acceptable and is in
fact, detrimental to the Rozelle community.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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This submission demonstrates that, despite the modifications to the proposal:
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The site and the proposed design are not so “unique” to justify putting aside the well
considered planning outcomes that Rozelle should remain a "small village and the
current State and Regional strategies for the locality or recently exhibited draft
documents such as the draft NSW Long Term Transport Master Plan.
The proposal will have significant and permanent detrimental impacts on Rozelle and
Balmain high streets.
The proposal fails in terms of its Urban Design and Architectural merit and would result
in poor amenity for future residents and users of the retail area.
The development would have significant impact on surrounding residential streets and
the future trading of the existing retail shopping strip characteristic of Rozelle.
The proposal will result in unacceptable impacts on the surrounding traffic network,
including Victoria Road.
The certainty of the Tiger’s Club returning to the site has diminished, reducing the FSR
bonus that may be considered because of the benefit of the Club to the community.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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2 The Strategic Context
2.1
Applicant’s Justification
The Department required the proponent to justify the height and density of the proposal in
the context of the site’s location. The proponent’s response is that the site is so unique, that
the strategic context of the site can be overlooked. The PPR includes:
Notwithstanding the reduction in scale and density of the development, the project itself
remains a significant proposal in terms of its development density and building height by
comparison to the surrounding context. Accordingly, it is anticipated that even in this
modified form, the Preferred Project will not satisfy many submitters’ concerns in relation to
the overall scale of the project.
The proponent’s justification for the proposed height and density under the PPR are the
“unique” attributes of the site. These unique attributes are described in the PPR to be:
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Its pivotal location at the intersection of the two major roads;
The location at the high point of the local precinct;
The significant land holding that makes high density development possible and the
ability to meaningfully contribute to housing supply needs; and
The historic association of the Balmain Tigers, an important social and community
facility for the local region.
Council’s response to these “unique” attributes of the site is provided below.
2.1.1
Attribute 1: Its pivotal location at the intersection of the two major roads
The identification of the project as a “Major Project” means that the project is potentially so
significant that local, numeric planning controls do not apply. Consequently, the status of the
higher level planning documents, in the form of State, Metropolitan and Regional policies,
becomes vital in providing an established framework within which the application must be
assessed.
The location of the site, at the intersection of two major roads, does not make the site
particularly unique in the Sydney Metropolitan context. However the location does mean
there are significant constraints that must be considered in the design of the proposal. The
impact of the location of the site, at the intersection of two major roads, means issues
regarding amenity impacts on proposed future residents and mitigation measures on already
at capacity traffic intersections need to be thoroughly considered. The proponent has failed
to respond to the constraints of the site as a result of its location on two major roads.
The location of the site, on a busy road, is also relevant in terms of assessing the potential of
the site in the context of the strategic planning framework guiding development in the
locality. The draft Inner West Subregional Strategy (the Strategy) under the Centres and
Corridors chapter, identifies Victoria Road as an Enterprise Corridor. The Strategy highlights
that: There are a number of roads in the Inner West Subregion with high volumes of traffic.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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These are not generally recommended for new housing development due to the health risks
and low amenity associated with traffic noise and vehicle emissions 1.
The development is proposed in an area that is not recommended for housing development.
The draft Subregional Strategy also includes that
The Inner West contains a number of busy roads that may be appropriate for Enterprise
Corridor zoning, such as Parramatta Road, Liverpool Road and Victoria Road. They provide
valuable spaces for local industrial services, such as automotive services, a range of retail
formats and often affordable spaces for businesses. Redevelopment within Enterprise
Corridors may only include residential uses where there will be acceptable impact from road
noise and pollution.
The recently exhibited draft NSW Long Term Transport Master Plan (the draft Master Plan)
has been prepared to be the guiding transport planning and policy document to support the
goals in NSW 2021 (the NSW State Plan). The aim of the draft Master Plan is to integrate
transport with wider economic, infrastructure, social, housing and land use planning
including the Metropolitan Strategy for Sydney and the State Infrastructure Strategy to
ensure NSW has a coherent overall approach to planning and growth. The final Master Plan
is expected to be delivered by the end of 2012.
Chapter 4 – Getting Sydney Moving Again, of the draft Master Plan, describes Sydney’s
transport challenges and the actions to ensure Sydney’s 46 strategic transport2 corridors
flow. These strategic transport corridors are vital to sustaining Sydney’s centres of
commercial and residential growth, supporting the transport needs of key industries and
helping Sydneysiders get to work each day and move freely around the City. The
Parramatta to Sydney via Top Ryde (i.e. Victoria Rd) corridor is currently the second most
congested road corridor in Sydney.
The draft Master Plan includes that:
The section of Victoria Road between Drummoyne and the Anzac Bridge carries an average
of around 75,000 vehicles each weekday across the Iron Cove Bridge. It is one of the most
congested road corridors in Sydney with average speeds below 20 km/h between Hunters
Hill and Rozelle. [Refer to Figure 1 below – extract of Figure 4.29 from the draft NSW
Transport Master Plan 2012] This section of road is also one of the busiest bus corridors in
Sydney, with 19 bus routes carrying an average 40,000 passengers across the Anzac Bridge
each weekday. With the recent opening of the new Iron Cove Bridge, improved transit lanes
on Victoria Road have improved bus flow, providing city-bound bus commuters with travel
time savings of up to 17 minutes in the morning peak period. Even so, there is still variability
in bus travel times of between eight and 10 minutes due to the volume of buses.
Forecast growth in this corridor is also high due to growth at Ryde and Macquarie Park,
inner Sydney and Parramatta. Forecasts suggest 37 percent growth on bus patronage. This
1
NSW Department of Planning (July 2008) Draft Inner West Subregional Strategy. Page 57
The draft NSW Long Term Transport Master Plan identifies 46 strategic transport corridors in
Sydney’s Greater Metropolitan Area. These corridors represent travel demands between Sydney’s
key activity centres and are where high concentrations of travel demand occur during peak periods on
all travel modes. Figure 2.3 of the Master Plan show these corridors.
2
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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corridor has a strong correlation with other corridors such as Parramatta to the CBD via
Strathfield and Macquarie Park to the CBD via Chatswood.
The draft Master Plan identifies that key bottlenecks – such as Victoria Road, Spit Bridge
and the Harbour Bridge – are at capacity.3
The State Government promises in the Master Plan that:
This draft Long Term Transport Master Plan provides measures that will address the causes,
and mitigate the manifestations of congestion. These measures go beyond addressing the
visible incidence of congestion and extend to the management of the State’s transport
systems as a whole*4. We will do this by:
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Accommodating land use, growth and urban renewal and ensuring land use policies
make a positive impact on congestion.
Council’s traffic consultants have reviewed the proposed Preferred Project and the traffic
and transport analysis prepared GTA Consultant’s for the proponent (refer to Section 3
below). Council’s traffic consultants do not conclude that the proposal will have a positive
impact on congestion, which is counter to the commitments of the NSW State Government’s
policy in relation to transport and land use planning.
Council’s Panel has advised that the proposed residential apartments are predominantly
orientated towards Victoria Road to the east and north and will be adversely affected by road
noise and pollution. In the Panel’s view, the apartments are compromised by traffic noise
and this is supported in the proponent’s Noise Impact Assessment which states that due to
the “high traffic noise levels” substantial glazing systems are required and balconies’ noise
reduction treatments need to be maximised. These requirements will most likely result in
continuous use of air-conditioning and an inability to enjoy sufficient noise amenity on
balconies.
Furthermore, the NSW Auditor-General’s Report - Volume Eight 2012 – Focus on
Transport and Ports, released on the 5 December 2012 has identified on p19 that Victoria
Road has the slowest average travel speeds in both the morning and afternoon peak periods
of all of the seven major routes to and from Sydney.
The Panel has advised that the proposal does not meet the requirements of SEPP 65 due to
a number of issues, including acoustic issues on the Victoria Road frontage. They are of the
opinion that this issue should be resolved in a manner that allows passive ventilation whilst
achieving noise and temperature comfort levels in the residential apartments. The residential
amenity will be compromised by heat gain and noise problems.
3
NSW draft Transport Master Plan 2012 – p.103
* P20, Managing Urban Traffic Congestion, Transport Research Centre, European conference of
Ministers of Transport.
4
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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Figure 1: Extract of Figure 4.29 of the draft NSW Transport Master Plan indicating minimum,
average and maximum AM peak travel speeds on key roads in Sydney.
2.1.2
Attribute 2: The location at the high point of the local precinct
The location of the site at the high point of the local precinct means that any development at
the site must be of exemplary design. The topography alone will add to the visual impact, let
alone two (2) x 24 storey towers in an environment characterised by 2 – 3 storey
developments.
The Council’s Panel has advised that:
The building mass and bulk is considered entirely inappropriate due to the great number of
negative impacts imposed on the surrounding area. The overshadowing is excessive and
will considerably reduce amenity to the neighbouring properties and public space.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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The deep podium building creates an internalised retail area which does not make a positive
contribution to the surrounding streets at street or upper levels. The monolithic podium to is
out of character and overbearing. The podium is designed with complete indifference to the
context and topography. This results in a building that presents a bulk and scale that is
overly dominant and out of scale with every other development on the Balmain and Rozelle
peninsula.
We respond to the proponent's argument that the site is so unique that they can ignore the
strategic planning context of the site. One of the unique attributes the proponent refers to for
the site is its location at the high point of the local precinct.
The proponent argues that the site is unique due to its location at the high point of the local
precinct. This in itself is not justification for a development of the scale proposed. The
previous DCP and LEP for the site had considered the regional and local context and the
topography and concluded that the maximum desirable height would be 7-12 storeys. This
was a result of a detailed study from various view points and the visual impact when viewed
from a distance. Further the building heights proposed were of different scales in order to
establish a single dominant element. The height proposed is not the outcome of 3-D
planning study of inner metropolitan Sydney or even the impacts on the local context, but
one that is capped only by the limits of the flight path overhead.
The DCP and LEP also recognized the potential contribution that the site could make to the
retail activity on Darling Street through the integration of a central public open space and a
strong open connection to Darling Street. In return for the public benefit a considered
increase in the building height was considered reasonable. The current proposal does not
provide this public benefit.
The residential towers are too close together. Under the RFDC buildings of this height
should have a minimum of 24 metres building separation. Victoria Park in the City of Sydney
is a better example with 60m distance required between residential towers to reduce loss of
amenity and overshadowing. Overlooking and overshadowing remain series issues with this
proposal. Any proposal for extra height in this area would require excellence in all aspects of
the design and good public benefits. This proposal does not achieve either.
A series of photomontages were commissioned by Council to demonstrate the possible
contextual outcomes of the proponent’s Preferred Project and the visual impact of the
towers, given the site’s location at the high point of the locality. Photomontages 1 – 4 on the
following pages illustrate the visual impact of the development on the locality. A complete set
of photomontages commissioned by Council are provided at Appendix A.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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Photomontage 1 | View from Moodie Street, corner of Waterloo Street, Rozelle.
Photomontage 2 | View from the corner of Hamilton and Merton Streets, Rozelle.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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Photomontage 3 | View from Victoria Road, near Terry Street.
Photomontage 4 | View from the corner of Darling and Denison Street, Rozelle.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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2.1.3
Attribute 3: The significant land holding that makes high density development
possible and the ability to meaningfully contribute to housing supply needs
A higher density at the site is potentially possible if the impacts of such a development can
be mitigated to protect the amenity of adjoining residential streets and the local economy of
Rozelle. This is in addition to addressing impacts on one of Sydney’s most constrained
strategic transport corridors and the impacts of Victoria Road on the amenity of future
residents in terms of acoustic and pollution. As outlined above, Council’s Panel have
commented that the density of the PPR is inappropriate due to the number of negative
impacts that will result on the surrounding area and the amenity of future residents.
In terms of contributing to Sydney’s housing supply needs, as outlined in Council’s original
submission dated June 2012, Council’s draft LEP 2011 is based on the outcomes of the
Council’s Stage 1 – Residential Strategy. The housing figures for the site, in the Residential
Strategy, are based on the NSW Government’s Metropolitan Development Program (MDP)
(2008/2009), where the yield from the site was identified at 130 dwellings. In the 2010/2011
MDP, the site is no longer identified as a major site.
The PPR includes that the building envelope of the Preferred Project has been informed by
two reference points:
Maximum: noting comments in respect of safeguarding prescribed airspace zones the
maximum height of the proposal is constrained by the PANS-OPS level (RL 124).
Minimum: under the local planning controls development may be constructed to a height of
RL52m (equivalent to 14 storeys).
A height at the upper limit of these two reference points has been adopted (RL 122m). This
has informed the overall FSR of the project (5.3:1).
The objective of the floor space ratio control under Clause 4.4 of the draft Leichhardt LEP
2011 is:
4.4 Floor space ratio
(1) The objectives of this clause are as follows:
a) to ensure that the bulk and scale of development is compatible with the character,
form and scale of the neighbourhood, and
b) to minimise adverse environmental impacts on adjoining properties and the public
domain
Typically, higher FSR controls than envisaged by environmental planning instruments are
supported where impacts on the surrounding neighbours and locality have been mitigated
through best practice urban design. As outlined in the PPR, the proponent has derived the
Preferred Project FSR by simply designing a building to the PANS-OPS limit, rather than
designing to protect the amenity of the surrounding locality or to ensure the amenity of future
occupants of the development.
The Council’s Panel has stated that:
The proposal continues to be an ill-conceived ambit claim unrelated to the Sydney
Metropolitan Strategy, the DCP or the requirements of SEPP 65. The Panel considers this
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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proposal would have large and long lasting detrimental impacts on Rozelle. The Panel can
find no positive outcomes for the residents and businesses within the local area that would
arise due to this proposal.
The site specific DCP and LEP provide for increased density provided the objectives of that
Plan were met. These objectives (agreed to by the previous owner of the site) were:
(a)
(b)
(c)
(d)
(e)
the development integrates suitable business, office, residential, retail and other uses
so as to maximise public transport patronage and encourage walking and cycling,
the development contributes to the vibrancy and prosperity of the Rozelle Commercial
Centre with an active street life while maintaining residential amenity,
the development is well designed with articulated height and massing providing a high
quality transition to the existing streetscape,
the traffic generated by the development does not have an unacceptable impact on
pedestrian or motor vehicle traffic on Darling Street, Waterloo Street and Victoria
Road, Rozelle,
any residential development at street level has a frontage to Waterloo Street, Rozelle
and, when viewed from the street, has the appearance of no more than three storeys.
In addition, there were other public benefits through improved public domain and public
space was to be provided. The current proposal provides no public benefit in return for the
substantial development that is provided on the site.
2.1.4
Attribute 4: The historic association of the Balmain Tigers, an important social
and community facility for the local region
Council supports the return of the Club to the area and this site.
However, this PPR does not provide a fully fitted out Club or propose a peppercorn rent for
the space (there is no such commitment in the Statement of Commitments). Council
understands that the Club now has a debt in excess of $10million to the proponent and it
seem unlikely the Club will be able to fund a relocation back to the site and pay commercial
rent for the space.
Importantly, given the uncertainty of the Club returning to the site, Council’s draft LEP 2011
recognises that the Club’s role at the site is less certain. As a result, bonus FSR and height
provisions are not included in the draft LEP and a density more consistent with that of a
Local Centre or Village is proposed, that is a density of 1.5:1. Nevertheless, Council has
indicated a willingness to consider a revised planning proposal for the site that is compatible
with established centres typology for the locality.
2.2
Precedent Cases
The proponent compares the site to a number of other sites consisting of high rise towers
outside of major centres which are greater in height, mass and scale than their local context.
The examples the proponent has chosen as “precedent cases” have little in common with
the proposal, except that they all include substantial towers.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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Table 1: Proponent’s “precedence cases” compared to the Preferred Project
Development
Rose Corp – 150
Epping Road, Lane
Cove
Site location
Epping Rd, land zoned
industrial. Site adjoins
light industrial units
and bushland.
FSR
1.1:1
Stamford Grand
Hotel Cnr Epping &
Herring Road, North
Ryde
Cnr of Epping Road
and Herring Road,
gateway to Macquarie
Park corridor.
2.13:1
North Ryde Railway
Station
Located adjacent to
business park and
opposite a cemetery
Unknown
Comparison to Rozelle Village
ƒ The Epping Road site is not located
in an existing “village” setting.
ƒ The Epping Road site is not located
in a Heritage Conservation Area
(part of Rozelle Village site fronting
Darling St is in HCA)
ƒ The Epping Rd site is not located
on a “constrained” transport
corridor.
ƒ The proposal is not adjacent to any
other residential development.
Consequently, there are no impacts
such as overshadowing on
surrounding areas.
ƒ The Stamford Grand site is not
located in an existing “village”
setting.
ƒ The Metropolitan Plan identifies
Macquarie Park as a ‘Strategic
Centre’ and as the northern anchor
of the ‘Global Economic Corridor’ of
concentrated jobs and economic
activities stretching between
Macquarie Park and Port Botany.
Macquarie Park is more specifically
classified as a “specialised Centre”
under the Plan.
ƒ The Stamford Grand site is not
located on a “constrained” transport
corridor, but is located within 400m
of a train station.
ƒ The orientation of the site and the
positioning of the buildings is such
that, the majority of overshadowing
will fall across Epping Road rather
than residential uses, with sufficient
daylight access to adjoining
properties maintained during the
critical winter solstice.
ƒ The North Ryde Station site is not
located in an existing “village”
setting.
ƒ The North Ryde Station site is not
located on a “constrained” transport
corridor, but is at a train station –
the proposal is specifically
described as Transit Orientated
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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Development
Site location
FSR
23 – 37 Lindfield Ave,
Lindfield
Located in a “small
village” adjacent to
heritage items (or
conservation area).
3.84:1
Comparison to Rozelle Village
Development.
ƒ DGR’s have been provided. No
proposal has been submitted at this
time.
ƒ The Lindfield site is located in an
existing “village” setting as defined
by the draft North Subregional
Strategy.
ƒ The Lindfield site is located
adjacent to a heritage conservation
area (or items).
ƒ The Lindfield site is not located on a
“constrained” transport corridor, but
is opposite Lindfield train station –
in recognition of location near
unconstrained transport = additional
FSR.
The Lindfield example is the only case provided by the proponent that is potentially
comparable to the subject site, being located in a “village” as determined by the hierarchy of
centres for the Sydney Metropolitan region as outlined in the Metropolitan Plan. The Lindfield
example, however is not located on a constrained transport corridor. In the Lindfield
example, the Department gave consideration to the built form of the proposal and
compatibility to the surrounding locality. The DoPI’s report to the Planning Assessment
Commission includes: The Department considered that the proposed height, bulk and scale
for this proposal is most appropriately tested through an assessment of:
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density
proposed height and bulk of the built form; and
compatibility with the surrounding locality.
The Department has considered the merits of the proposal in accordance with the objects of
the EP&A Act and ecologically sustainable development, also taking into consideration the
issues raised in all submissions. The Department has determined that the proposed bulk and
height of the development is generally compatible with the character of the surrounding
locality (subject to recommended conditions).
The Department concluded that the proposal, at its scale of 3.84:1 and 5 – 6 storeys in
height could be supported on the basis that it would provide a broad mix of apartment types
within the existing Lindfield Town Centre adjoining excellent public transport services and an
opportunity to revitalise the Town Centre with upgraded retail services.
As outlined in the PPR, the Rozelle Village proposal is not compatible with the local context
of the site within a “small village”. Its proposed density (5.3:1), height (2 x 22 storey towers
above 2 – 3 storey podium) and built form will have impacts on the amenity of surrounding
residential properties; the amenity of future residents; unacceptable traffic impacts on an
already constrained corridor and negative impacts on the existing Rozelle commercial village
hub. The proposal is unlikely to act as a catalyst to revitalize the existing “small village”.
Peter Leyshon of Leyshon Consulting has advised:
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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…the reduction in floorspace may well have had a detrimental effect on the extent to which
the proposed development “connects” with Darling Street Rozelle. The revised plans indicate
a short retail arcade leading from Darling Street and opening out into an internal square
without significant “activation” by retail tenancies. As a consequence of this, the proposed
development breaks traditional rules of retail development which holds that that shoppers
should be "engaged" by a continuous facade of retail tenancies which maintains their
interest in draws them from the development through to Darling Street and vice versa.
… the amended design will not encourage shoppers to come up from the two lower levels of
the proposed development, which accommodate the supermarket and mini-major
respectively, to interact with the existing retail shops operating on Darling Street.
Thus the proposed development while having an impact (according to urbis) of - 5.7 % to 11.2 % on Darling Street does not significantly offset this impact by acting as a new effective
“anchor” to the surrounding retail precinct.
The overall negative impact of the proponent’s Preferred Project in this context is
unacceptable and will create considerable issues in how it relates to and impacts upon the
existing and future landform of Rozelle.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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3 Traffic and Parking
The development goes beyond any real or reasonable expectations for the site.
Consequently, the traffic implications as a result of the development are beyond anything
that has been contemplated for the site by Council. Accordingly, Council’s technical staff
reviewed the Transport Management and Accessibility Plan Preferred Project Report (Issue
C) prepared by GTA Consultants. In addition, a technical review has been prepared by
Council’s traffic consultants, Arup. Council’s technical staff and Arup have identified a
number of areas of concern relating to the traffic access and car parking for the Preferred
Project, as outlined below.
3.1.1
Assumptions Made by Consultants Regarding Likely Traffic Generation
The consultant traffic study addresses the key issues associated with traffic generated by
the development and includes an assessment of relevant potential new developments (with
the exception of the Temporary Exhibition Centre, which was not proposed when the study
was prepared).
The following assumptions require further explanation before Council could be completely
satisfied with the traffic calculations:
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Based on advice from Urbis; GTA have assumed that the development’s retail
component will be “a local shopping centre and much less of a destination centre”.
Concern is expressed that this is an oversimplification of the nature of Rozelle. In
addition to the attraction of the development’s proposed major supermarket, club and
gymnasium/health club, the existing Rozelle shopping strip contains numerous
speciality stores which have region-wide reputations (eg Herbies Herbs and the
Essential Ingredient). Consequently, it would seem unusual that a new development
would not attract a number of similar speciality stores which would attract from further
a field, with the possibility that Rozelle could continue to grow in this manner. (GTA P12)
The traffic distribution assumed in the Transport Management and Accessibility Plan
appears to indicate that the 22% of traffic likely to travel from the north (ie the
secondary retail catchment) have “replaced the same number of trips travelling from
Iron Cove to Anzac Bridge and visa versa”. This implies that the applicant’s modelling
has assumed that the secondary catchment will only generate “passer-by” traffic and
not attract additional patronage in its own right. (GTA - P13)
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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3.1.2
The traffic modelling appears to ignore traffic generated by the Cruise Passenger
Terminal (GTA - Table 3.2 and GTA - P18) indicating that “the cruise terminal would
not generate significant levels of traffic at the same time as the peak periods for traffic
generation of the Preferred Project”. This is contrary to the current Sydney Ports
berthing schedule (for Barrangaroo and the Overseas Passenger Terminal) which
indicates that for the months;
– 14 November 2012 – 13 December 2012 … 61% of ships will arrive during the AM
peak period;
– 1 April 2013 – 30 April 2013 … 68% of ships will arrive during the AM peak period.5
The modelling was unable to include the recently proposed temporary exhibition centre
as it was not announced until after the modelling had been completed.
The modelling appears to have assumed 24/7 clearways on Victoria Road, and the
removal of kerbside parking on Darling Street during peak periods including Saturday
Midday peak, which have not been approved would have a significantly detrimental
impact on local shops.
Traffic Generation
Traffic generation of the Preferred Project represents a significant reduction in the number of
peak period vehicle movements (in comparison to previously proposed developments. The
reduced floorspace (55,000m2 to 43,500m2) in combination with the reduced on-site parking
provision (reduced from 834 to 509 spaces) is better but still does not provide an acceptable
impact on Victoria Road or local streets
3.1.3
Other Considerations
Other considerations relating to the traffic and transport assessment of the Preferred Project
include:
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The impact of additional Traffic in Waterloo Street, particularly in relation to right turn
prohibitions likely to be imposed on vehicles exiting the development onto Victoria
Road.
Darling Street/Waterloo/Belmore intersection and associated queuing, particularly the
applicant’s proposal to remove kerbside parking in Darling Street to alleviate this
queuing. It is considered that the applicant’s proposal, to replace Darling Street’s
kerbside spaces with short-stay spaces in the development’s basement, is not
appropriate as these spaces will not be readily available for patrons of shops which
front Darling Street.
The impact of increased traffic on Terry and Wellington Streets and proposals to
remove parking in Wellington Street.
Pedestrian and cycle access along the Victoria Road frontage does not appear to be
fully resolved.
Increasing delays on Victoria Road have the potential to impact on buses, which in
turn may reduce the attractiveness of buses and so reduce the potential for increased
public transport mode share for the development’s residents and patrons.
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It should be noted that the Sydney Ports schedule does not differentiate between domestic and
international cruise ships in this data
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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Modelling indicates that the cumulative impact of all developments (with the exception
of the temporary exhibition centre – not modelled) will result in saturation of the
Victoria Road/The Crescent intersection during the PM peak6.
The consultant’s assessment of cumulative traffic impacts of all developments
indicates that adjacent local streets will receive increased traffic movements, as
indicated below.
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Table 2:
streets
Assessment of cumulative traffic impacts of all developments on adjacent local
Modelled % Traffic Increase
Street
Waterloo Street
Terry Street
Darling Street (west of
Waterloo Street)
Moodie Street
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AM Peak
160%
44%
23%
PM Peak
83%
20%
25%
Saturday Midday Peak
69%
23%
38%
40%
33%
27%
The capacity of existing bus services to cater for the increased demand envisaged by
the traffic study does not appear to have been examined.
Care should be taken that the reduction of on-site parking should be supported by
measures to encourage lower private car ownership to reduce the likelihood of
overflow parking using adjacent residential streets. While the consultant study
proposes a green travel plan, it is suggested that additional details on its operation and
management should be provided.
3.2
Arup traffic and parking assessment
3.2.1
Vehicle access
Vehicular access to the site concentrates retail and commercial vehicle movements to and
from Victoria Road with only residential parking being accessed from Waterloo Street. All
loading dock and servicing access is also from Victoria Road.
The Victoria Road site access is configured as a fourth (western leg) to the Wellington Street
intersection with full traffic light control. The right turn movement from Victoria Road into the
site is banned which requires vehicles entering from the north to use Terry Street to access
the site via Wellington Street. The Wellington Street cross movement to enter the site is
offset by some 12m. The pedestrian crossing on Victoria Road is moved east to allow for the
site driveway. This will be confusing to drivers and potentially unsafe given that there is only
one lane entering and three lanes exiting the site.
The RMS has requested that only entry movements be permitted from Victoria Road due to
the additional phase that exit traffic would add to the traffic lights reducing the green time for
Victoria Road traffic and bus flows. The Leichhardt Development Control Plan – Part D1.0
Site Specific Controls, Balmain Leagues Club Precinct (2008) requires that all egress for
retail, commercial and servicing be to Victoria Road. The Preferred Project has adopted this
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Note this intersection is already is near capacity in both peak periods and is likely to reach capacity
without the addition of traffic from Rozelle Village. Consequently route choice decisions may be made
further afield resulting in a diversion of some traffic to other streets.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
18
arrangement by allowing only left turn traffic to exit the site and banning the right turn
movement out of the site. This means that city bound traffic exiting the site will need to use
the surrounding residential streets. The quickest routes would be via Denison Street, Alfred
Street and Gordon Street or Darling Street, Nelson Street and Evans Street to gain access
to Victoria Road. This places pressure on narrow local streets reducing resident amenity.
3.2.2
Victoria Road deceleration lane and Porte Cochere
The entrance to Darling Lane and the adjacent porte cochere indicates vehicles will be
entering and leaving these driveways immediately next to each other. This is considered a
confusing and potentially unsafe arrangement. In addition, the driveways occur at the start of
the deceleration lane which will also be confusing for Victoria Road traffic as drivers entering
this driveway will need to slow down in the left traffic lane prior to the deceleration lane.
Tailing drivers will expect left turn traffic to be proceeding further down to the main car park
entry and hence the speed differential on this downgrade will be confusing for drivers.
Pedestrians on the Victoria Road footpath need to deviate in towards the building at this
location behind the deceleration lane and no details are provided on how pedestrians will be
treated in safe manner at this driveway location.
The porte cochere does not appear to include an adequate turn around facility for cars and
taxis and will potentially block up, especially if cars decide to wait on one side of the two lane
roadway. The drop-off and pick-up activity should occur within the basement in a nonticketed area. There appears to be no location for the community bus pick-up/drop off.
3.2.3
Cumulative Traffic Generation
The traffic modelling has been undertaken including anticipated traffic flows for all planned
developments that are serviced by the Victoria Road corridor. A bus travel time analysis has
been undertaken using the Paramics model. In the AM peak, eastbound city buses
experience a 9 second per bus delay and the buses westbound from the city experience a
18 second per bus delay due to the introduction of the fourth leg to the Victoria
Road/Wellington Street intersection. In the PM peak, the buses westbound from the city
experience a 30 second delay per bus. A significant component of the westbound delay in
both peaks results from the Rozelle Village traffic.
On Saturday, the modelling for eastbound buses assumes removal of on-street car parking
on the east side of Victoria Road. This improves bus travel times including development
traffic. In the westbound direction, bus travel times are increased by 1 minute 24 seconds.
However there has been no modeling based on retention of these spaces.
The intersection performance at Victoria Road /Darling Street has been modelled for car
parking removed in Darling Street on Saturday for the Rozelle Village scenarios. This shows
improved operation over the base model and base + cumulative other developments. There
is no indication of how the intersection performs if car parking is retained. For the PM peak,
the modelling indicates that this intersection deteriorates with the base + cumulative traffic
but then improves with the addition of Rozelle Village traffic. This outcome is not explained in
the report.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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It is noted that the cumulative analysis by GTA consultants does not include the proposed
Temporary Exhibition Centre, because it was not proposed at the time the analysis was
undertaken.
3.2.4
On-Street Parking
The traffic assessment assumes the removal of on-street parking in Darling Street and
Victoria Road on Saturday. These are considered to be crucial car parking spaces for the
ongoing viability of the strip retail on Saturday. The provision of short term spaces within the
basement will not provide the same level of service that currently exists.
3.2.5
Wellington Street
The report states that on-street car parking arrangements along Wellington Street have been
adjusted in the model to better reflect existing conditions. The existing left lane in Wellington
Street is a short 30m long lane which currently provides for left and right turning traffic. No
indication is provided in the report on whether the left lane is to be lengthened to
accommodate the additional straight ahead traffic accessing the Rozelle Village site.
3.2.6
Local Street Impacts
The Inner West Busway project along Victoria Road has already had an impact on the
accessibility into and out of some local streets along this section of Victoria Road. The
Rozelle Village development places increased traffic on local streets on both sides of
Victoria Road in order to gain access to the site. This will further reduce local accessibility for
residents and businesses in the precinct.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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4 Retail Impacts
Leyshon Consulting has undertaken a review of the proponent’s preferred project on behalf
of Council and advised as follows:
The current amended proposal reduces the retail floorspace by about 2,185 sq.m
Normally this is to be applauded as any reduction in floorspace theoretically reduces the
potential impact on retail centres/precincts in the trade area.
The decrease in floorspace is broadly as follows:
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Supermarket – 215 sq.m
Mini-majors – 950 sq.m
Specialties – 1,020 sq.m
The reduction in specialties is particularly beneficial as it will result in 10 to 12 fewer shops in
the proposed development compared to the previous proposal. That said, the development
is still likely to accommodate 20 to 25 shops in addition to the supermarket and proposed
mini major.
I reiterate comments previously provided to Council that at present the retail sector in
Australia remains very subdued and it is likely that existing retailers in Darling Street Balmain
and Rozelle are likely to be trading sub optimally. Inevitably there will be some impact from
the addition of 20 to 25 shops in this location.
Surprisingly the projected sales of the proposed retail component of the development have
only marginally reduced from $ 67.0 mil pa in the previous scheme to $65.7 mil pa in the
amended proposal. This is a decline in projected sales of only of -1.9% despite a decrease
in retail floorspace of about -21.7%.
The revised EIA prepared by urbis entitled: Roseville Village Economic Impact Assessment
October 2012, it does not provide a convincing explanation as to why the turnover of the now
proposed centre would only be slightly less than the previous proposal for a much larger
centre.
We remain unconvinced that the revised turnover has been estimated with any acceptable
degree of precision. It is unexplained why such a smaller development will capture almost
the same aggregate level of sales and in fact will trade at a much higher average rate (as
measured on a $ per sq.m per annum ) basis with no substantive change to the overall
tenancy mix or characteristics of the development.
Reference is made by urbis to the proposed removal of the "Target Urban" mini major and
the consequent provision of opportunities to cluster specialty food retailing around the
supermarket and increase scope for "some of the larger retail boxes at ground level to be
subdivided into smaller destination tenancies". We do not agree that these changes would
substantially alter the performance characteristics of this proposed centre to the degree
suggested.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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We consider that this change has been “engineered” solely to address the criticism of the
Economic Impact Assessment (EIA) which accompanied the previous application, that the
turnover rate for the then proposed development was too low by observed industry
standards to be credible.
In our opinion the reduction in floorspace may well have had a detrimental effect on the
extent to which the proposed development “connects” with Darling Street Rozelle. The
revised plans indicate a short retail arcade leading from Darling Street and opening out into
an internal square without significant “activation” by retail tenancies. As a consequence of
this, the proposed development breaks traditional rules of retail development which holds
that that shoppers should be "engaged" by a continuous facade of retail tenancies which
maintains their interest in draws them from the development through to Darling Street and
vice versa.
In our opinion, the amended design will not encourage shoppers to come up from the two
lower levels of the proposed development, which accommodate the supermarket and minimajor respectively, to interact with the existing retail shops operating on Darling Street.
Thus the proposed development while having an impact (according to urbis) of - 5.7 % to 11.2 % on Darling Street does not significantly offset this impact by acting as a new effective
“anchor” to the surrounding retail precinct.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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5
Urban Design
The Panel (Philip Thalis, Peter Smith + Kerry Clare) was constituted by Leichhardt Council
to advise on the design aspects of this major application for a large consolidated site in
Rozelle. This is the third Panel review for this site.
The Panel has also reviewed the Part 3A Application in relation to SEPP 65, which includes
ten Design Quality Principles and the requirements for a Qualified Designer (a Registered
Architect) to provided Design Verification Statements throughout the design, documentation
and construction phases of the project. The Residential Flat Design Code, published by
Planning NSW (September 2002) is also relevant to this review.
The following review of the new Rozelle Village proposal (October 2012) assesses the
appropriateness of its response to the above issues and against the objectives of the NSW
Government’s Metropolitan Strategy (2010).
5.1
1.
NSW Government’s Metropolitan Strategy
The 2010 Metropolitan Strategy does not recognise the Balmain Tigers site as being
within a Major Centre, Specialised Centre, Town Centre or Village. The Strategy
states that villages - which are considered to include a rule-of-thumb walking
catchment of 400 to 600 metre radius may benefit from additional shop-top housing,
low rise apartments and well-designed clusters around schools, child care centres,
parks or recreation areas. The area is noted within a “Small Village” with a density of
12-25 dwellings per hectare.
Comment: The development fails to support the Strategy in an appropriate manner by
proposing an overdevelopment for the local area.
2.
The Metropolitan Strategy also notes the Inner West contains a number of busy roads
that may be appropriate for Enterprise Corridor zoning, such as Parramatta Road,
Liverpool Road and Victoria Road. “They provide valuable spaces for local industrial
services, such as automotive services, a range of retail formats and often affordable
spaces for businesses.”
Comment: The shopping areas proposed lacks sound retail planning or a clear connection
to Darling Street or Victoria Road. The retail does not contribute to the existing streets and
has poor and circuitous vehicular and pedestrian access. This site has the potential to
positively contribute to the retail experience and become a catalyst for the retail in this part of
Rozelle. In order to do this there must be a strong visual and physical connection.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
23
3.
Redevelopment within Enterprise Corridors may only include residential uses where
there will be acceptable impact from road noise and pollution.”
Comment: The development will be subject to unacceptable impact from road noise and
pollution. The development will further exacerbate the traffic and pollution by creating
queuing through the local streets. This development appears to be inconsistent with
Planning NSW’s guidelines for development along main road corridors, and recent research
by the Heart Foundation (Increasing Density in Australia: maximising the health benefits and
minimising harm). The application does not demonstrate why this site is suitable or
adequately resolve how the residential component will mitigate against road noise and
pollution.
4.
The Metropolitan strategy has identified three types of corridors: economic, renewal
and enterprise corridors. Victoria Road has been identified as an Enterprise Corridor
with high traffic volumes (up to 80,000 vehicles per day) and can “accommodate a vital
range of economic roles, including local urban services, car yards, strip retail and
office uses. . . . Enterprise Corridors are areas which provide low cost accommodation
for a range of local and regional services, including start–up offices, light industrial,
showrooms, building supplies and retail, which benefit from high levels of passing
traffic (over 50,000 vehicles per day). They provide a valuable buffer between
residential development and the road.”
“There are a number of roads in the Inner west sub-region with high volumes of traffic.
These are not generally recommended for new housing development due to the health
risks and low amenity associated with traffic noise and vehicle emissions.”
Comment: The development is proposed in an area that is not recommended for housing
development. The proposed residential apartments are predominantly orientated towards
Victoria Road to the east and north and will be adversely affected by road noise and
pollution.
5.
Small villages under the strategy should not detract from the strengthening of the
identified Strategic Centres. The Metropolitan strategy outlines some key aspects of
successful Strategic Centres as:
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accessible and pedestrian friendly;
providing good public transport options;
containing high–level jobs, learning opportunities and cultural activities; and
having attractive and safe public domain spaces.
Comment: The site is inappropriate for the proposed land use and density and will have
serious amenity, economic and traffic impacts to the detriment of the local area.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
24
5.2
The Department of Planning + Infrastructure
Schedule 1 - Fundamental Issues to be Addressed
The Department of Planning and Infrastructure noted in its assessment of the previous
proposal that the:
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Building Height and Scale of the building and podium were unacceptable within the
building’s context, and
Density of the proposal was excessive and more generally related to that of a Major
Centre.
Schedule 1 requests a more appropriately scaled development in its context.
Panel Comments
Although the proposal has been somewhat reduced in size and replanned to some extent it
is the Panel’s opinion that the development does not meet building height, scale and density
requirements or SEPP 65 standards due to the following inadequacies:
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severe over shadowing of the local area
overshadowing of the southern tower by the northern tower
proximity of residential towers which will overwhelmingly appear as one building from
the majority of viewpoints. The height and bulk is unrelated to the character of Rozelle
and considered an inappropriate precedent for the future character of the area
residential car park on the lowest basement levels is considered a very low amenity for
residents due to travel distance
the new infill retail buildings to Darling Street do not demonstrate design excellence or
make a significant contribution to the existing streetscapes.
the basements design has several problems and should align to the new boundaries
along Victoria Road without any encroachment under the 3m setback and dedication.
The basements should be set back 1m from the boundaries along Waterloo Street to
create viable deep soil areas.
the large areas for driveways has significant negative impacts on pedestrian and
streetscape amenity
there is no clear or compelling merit argument that would justify such an inequitable
increase in floor space (the existing site specific DCP already envisages FSR’s and
heights substantially higher than anything in the area – this proposal goes well beyond
those heights and volumes, the public benefit of the increased floor space was
intended to be the creation of a public space open to the air and a strong retail
connection to Darling Street.
the apartments generally have issues of lack of cross ventilation, a key requirement of
the RFDC associated with SEPP 65
access to natural ventilation via opened windows will subject apartments to undue
traffic noise
the proposed solar array will be extremely inefficient due to overshadowing
the high proportion of apartments that do not have cross ventilation. Many other
buildings of similar scale throughout Sydney are able to obtain well over 75% cross
ventilation
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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the high number of bedrooms that have compromised access to light and ventilation
(snorkel bedrooms)
the high number of apartments with single orientation
the high number of one bedroom apartments that do not have a window for the
bedroom
vastly excessive areas of fixed, unshaded, west facing glass to approximately one third
of the apartments
unshaded reflective glass curtain wall systems are considered inappropriate due to the
added need to air-condition. Reflective glass also reduces the ability for occupants to
see out at night as the surface becomes mirror-like to the interior. Large reflective
areas are likely to cause problems to other people in the area.
proximity of the towers, which does not comply with the RFDC (24m for towers of this
height)
acoustic issues on the Victoria Road frontage should be resolved in a manner that
allows passive ventilation whilst achieving noise and temperature comfort levels in the
residential apartments. The residential amenity will be compromised by heat gain and
noise problems
generally the landscape provisions are not adequate for the increased population that
is proposed. The substitution of the central public open space as required by the DCP
by one extremely small light court (approximately 9m x 3m) is entirely unacceptable
and does not deliver the public benefit anticipated for the site
safety and security concerns in the public domain arising from the site planning and
built form including footpaths to both Victoria Road and the through site link which are
in the form of undercrofts lacking surveillance from above; the disproportionately few
uses at street level to activate the street and lane due to internal levels not related to
the sloping streets; the configuration of the podium has insufficient contact and
surveillance to the street – a particular concern where there is a licensed club as part
of the proposal
poor entrances to the residential towers. The entry for Tower B is adjacent the truck
entry for deliveries for the retail and supermarket, deep within a dog-legged recess.
The entry for Tower A appears that it is part of the centre court and food court.
social consequences of 311 apartments, a large retail area, a licensed club, 5 levels of
car parking do not appear to have been adequately considered regarding the
relationship of these elements to each other, and of even more consequence, the
negative effects on the local area
shortcomings of the aesthetics of the podium and its relationship with the surrounding
buildings and streets.
tower A overshadows the photovoltaic array.
5.3
The Department of Planning + Infrastructure
Schedule 2 - Other Key Issues to be Addressed
5.3.1
Panel Comments
Traffic + Parking
For reasons outlined below the Panel is of the view that Traffic and Parking issues have
been inadequately addressed.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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Retail Impacts
For reasons outlined below the Panel is of the view that retail impact issues have been
inadequately addressed.
Urban Design
For reasons outlined below the Panel is of the view that urban design issues have been
inadequately addressed.
5.3.2
Detailed Review
Public Domain Interface / Context
This is a major application for a large consolidated site in Rozelle. The current Leichhardt
Council DCP for this site includes clear guidelines in relation to public domain and
importantly the creation of a connecting ground plane to Victoria Road, Darling Street and
Waterloo Street. The intended open public space in the centre of the large consolidated
block is described in the DCP and the surrounding building envelopes are arranged to
provide definition and appropriate sun access to this space.
The arrangement of the public space with multiple on grade connections from the central
public space to Waterloo Street, Victoria Road and a wide link (open to the sky) to Darling
Street would provide a strong connection to the existing retail.
The current Part 3A Application has not attempted to comply with the DCP massing, height,
floor space or open space requirements. Accordingly the proposed building envelopes are
considered excessive as they cause the following negative impacts to the public domain.
Victoria Road
Negative impacts continue in this new proposal due to the large expanse of driveways on the
Victoria Road frontage including the slipway and several truck and car driveway entry and
exits. The slipway takes up existing public footpath reserves and removing the possibility of
viable street trees.
The scale, detail, colours and materials of the podium design are considered bland and the
proportions remain monolithic within the streetscape of Rozelle. Rozelle and the Balmain
Peninsula are characterized by the fine grain of the built form.
The small recessed residential entry in a deep undercroft off Victoria Road adjacent to truck
entry, car entry and slipway is considered entirely unacceptable. Entry for the residential
components on this site would be far better placed off Waterloo Street.
Entrance to the supermarket should be announced with a generous opening that visually
connects through the site to Waterloo Street and is predominantly open to the sky.
The mini-major embedded at car park level cannot add to the street vitality. Instead it is
orientated to those people coming to and leaving the centre by car. As such it will detract
from Rozelle's street life, adding circulating vehicles rather than pedestrians.
The transition to the northern neighbour has not been well considered. The bulk of the
podium building has no connection with the existing character of the street and would set an
undesirable precedence for the future character of the street.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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The dedication to Council of a 3m footpath width is considered a minimum and preferably
this is clear of bus shelters and the like. The Panel strongly advises that the footpath be
dedicated in perpetuity to Council and that the basement levels (at all levels) are set back to
the same alignment.
The dedication to Council should extend for the full frontage to this important Sydney main
road. This would allow the long-term resolution of services and to allow continuous deep soil
for the trees. It would avoid obvious ongoing maintenance and liability issues such as failure
/ replacement of waterproof membranes that would disrupt the public footpath and lead to
the loss of street trees. The dedication would extend to future development sites on either
side of this site.
Waterloo Street
Apart from increased traffic impacts which are discussed separately the SoHo apartments
need to be stepped with the fall of the street to retain direct connection and activity, instead
the bland architecture of the podium is continued along Waterloo Street with the
predominant street front material being precast concrete with surface treatment of a single
colour. The large level change to the interior of the podium has not been addressed and it
continues to reduce visual permeability and ease of connection due to the large number of
stairs. The monolithic presence in no way relates to the finer scaled rhythms of this street
Darling Street
The Darling Street connection has been further downgraded since the previous proposal.
The arcade is now a single storey ramped retail space with a concrete undercroft (due to the
full width medical centre on Level 1) and connects into a ‘forecourt’ which is covered over by
the upper level tennis court with tall netting, along side the undercroft space of porte cochère
/ taxi drop-off and turn-around.
The proposal does not respond to the fine grain character of the existing properties. The
street frontage on Darling Street is not maintained but sets in an undesirable 1.5 metres
(approx.) which interrupts the established shopfront line. Negative impacts include bland
architecture and large areas aluminium grille facade. The arcade does not benefit from toplighting.
Overshadowing of the south side of Darling Street for lengthy periods by the proposed
towers will noticeably reduce the amenity of the north facing shops in this significant local
strip-retail area.
Retail impacts - the poor nature of the arcade, the poor use of Darling Lane, the poor retail
placement and circulation, the embedded bi box tenancies, and the poor access and egress
to parking and associated traffic issues will have serious impacts on this development and
the local retail offer.
The proposed removal of on-street car parking in Darling Street (required for the new traffic
volumes generated by this proposal) will have negative impacts on the existing retail. Traffic
movement and availability of on-street parking is a fine balance that is self regulating in
many local retail neighbourhoods. The addition of a left turn lane, longer traffic waiting
times, and reduced parking will upset the current balance and therefore amenity and
viability.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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Darling Laneway
Darling Laneway is an area that, under the site specific DCP, has great potential to make a
positive contribution to the amenity and economic viability of the Rozelle neighbourhood by
increased pedestrian connectivity, possible ‘through’ retail from Darling Street, access to
northern sun, and enough separation from traffic to be conducive to outdoor dining or the
like. The current design of the podium and towers will dominate and overshadow the lane.
The proposal for a taxi drop-off / porte cochère and vehicle turn-around in effect creates
another double driveway across the Victoria Road footpath with a large undercroft driveway
space of extremely poor character separated by level change and balustrades from the lane.
This proposal provides no benefit to the lane, and is a poor neighbour to the existing Darling
Street properties adjoining.
There is not adequate space for turning of any vehicle within this space.
Satisfactory evidence of retail viability has not been provided. The opportunity for an
amenable and equitable lane running at the rear of existing shops and connecting 3 streets
has been ignored. Such a lane could make a vital addition to the centre’s public domain, and
enable a diversified range of retail frontages.
Open Space
This proposal constitutes a huge reduction in area from DCP ground level public space,
vastly reduces natural permeability, and creates deep internal spaces under buildings.
These are not courtyards but atria that serve as retail circulation. Spaces are overshadowed,
subterranean and disconnected where the DCP anticipated an on-grade landscaped public
space open to the sky.
Built Form and Scale
The building mass and bulk is considered entirely inappropriate due to the great number of
negative impacts imposed on the surrounding area. The overshadowing is excessive and
will considerably reduce amenity to the neighbouring properties and public space. Heights
more consistent with the DCP are more supportable. Any argument for greater height
should be a result of further minimising the tower footprints, silhouette and separation
distances. The architects' concede that the building depth is "approximately 25 metres"
(p47), whereas the RFDC stimulates 18 metres maximum depth.
The deep podium building creates an internalised retail area which does not make a positive
contribution to the surrounding streets at street or upper levels. The monolithic podium is
out of character and overbearing. The podium is designed with complete indifference to the
context and topography. This results in a building that presents a bulk and scale that is
overly dominant and out of scale with every other development on the Balmain and Rozelle
peninsula.
The residential towers are too close together. Under the RFDC buildings of this height
should have a minimum of 24 metres building separation. Victoria Park in the City of Sydney
is a better example with 60m distance required between residential towers to reduce loss of
amenity and overshadowing. The overshadowing of the apartments by the building within
the development are cause for serious concern. Any proposal for extra height in this area
would require excellence in all aspects of the design and good public benefits. This proposal
does not achieved either.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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5.3.3
1.
The Department of Planning + Infrastructure
Schedule 3 - Additional Information Required
An assessment of alternative options for pedestrian access across Victoria Road.
Comment - This has not been provided. The Applicant’s report (Appendix Q) notes that
street level pedestrian crossings are the preferred outcome. The report does not directly
assess traffic impacts in relation to crossings or increased waiting times for pedestrians.
The report refers to Victoria Road as an urban street rather than addressing its ranking as an
Enterprise Corridor in the Metropolitan Strategy.
The proposed options for public connections and through-site linkages at ground level on
balance have not been significantly improved.
2.
Redesign of the footpath along Victoria Road to be clear of columns and have
adequate width.
Comment - Although the columns have been removed the slipway and vast width of
driveways has not improved. The addition of the taxi drop-off increases the driveway width.
The footpath design is considered exceptionally poor and this is further weakened by the
relentless facade, the absence of street trees and the reduced width due to the slipway.
3.
An assessment of the capacity of existing services and need for additional services
and open space
Comment - the provision of a childcare, and the commercial space for a medical centre and
the Leagues Club is not considered of sufficient benefit to warrant the severe reduction of
public benefits. These commercial uses could be accommodated on the site in a way that
retains the public benefit anticipated by the DCP / LEP.
4.
A revised Noise Impact Assessment.
Comment - This has been provided (Appendix J). In the Panel’s view the apartments are
compromised by traffic noise and this is supported in the Applicant’s report which states that
due to the “high traffic noise levels” substantial glazing systems are required, and balconies’
noise reduction treatments need to be maximised. These requirements will most likely result
in continuous use of air-conditioning and an inability to enjoy sufficient noise amenity on
balconies.
5.
Construction impacts, storm water runoff, staging.
Comment - the Panel defers to Leichhardt Council’s assessment of these impacts.
6.
Clarification of impacts in relation to overlooking -
Comment - There remains substantial overlooking impacts within and to the surrounding
neighbourhood
7.
Material and colour of external finishes
Comment - insufficient improvement has been achieved
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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8.
ESD initiatives
Comment - entirely inadequate. Air-conditioning will be required to achieve amenity for
apartments. By the Panel's calculation, there are too many single-orientation apartments,
including;
the 5 SoHo units are single orientation south-west
5 / 13 on level 3
10 / 18 on levels 4 - 8
8 / 16 on levels 9 - 20
2 / 8 levels 21
0 / 8 levels 22 - 23
one per floor in each tower that are orientated south-west (levels 4 - 20, plus one on level 3).
The applicant claims that 69% of units are cross-ventilated (p51). In the Panel's opinion the
percentage is actually 50% (158 / 316) - unacceptable in terms of the RFDC minimum
requirement for 60% cross-ventilated. With tower forms on such a large site, the Panel would
have expected from its experiences to have achieved 80 - 90% cross-ventilated units.
9.
Compliance with the Residential Flat Code
Comment - Inadequate. See previous comments in this report.
5.4
DRP Conclusion
The proposal continues to be an ill-conceived ambit claim unrelated to the Sydney
Metropolitan Strategy, the DCP or the requirements of SEPP 65. The Panel considers this
proposal would have large and long lasting detrimental impacts on Rozelle. The Panel can
find no positive outcomes for the residents and businesses within the local area that would
arise due to this proposal.
The DCP and LEP provide for increased density on this site compared to adjoining site, but
in return a public benefit through improved public domain and public space was to be
provided. The current proposal provides no public benefit in return for the substantial
development bonus provided on the site.
As detailed above, the Panel has significant concerns about the scheme’s shortcomings,
and cannot support the Part 3A Application in its current form.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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6 Voluntary Planning Agreement
The VPA relating to the DA before the JRPP included the following benefits to offset the
impacts of development, in addition to s.94 contributions:
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$500,000 for community grants
$250,000 for upgrading of surrounding roads and footpaths
Home delivery service
Community shuttle bus
Pedestrian Bridge across Victoria Road
Pedestrian link to Darling Street
Bike facilities
Community car share scheme
Employment for Aboriginal and Torres Strait Islander people during construction
Taxi pick up and drop off area
A review of the (original) PPR reveals that the current VPA was included as an appendix to
that application and the draft Statement of Commitments undertook to negotiate a revised
VPA with Council. At page 112, the Application listed the benefits proposed under the VPA
and stated:
The VPA does not form part of this Part 3A application but the details of the agreement are
generally relevant to the current proposal (being for a high density, mixed use development).
The proponent remains committed to delivering the public benefits outlined in this existing
VPA although it is recognised that some modification may be required to reflect the current
proposal. Any changes deemed necessary to the VPA to reflect the current proposal will be
negotiated with Leichhardt Council.
The recently amended PPR also amends the draft Statement of Commitments, at page 27,
the report states:
The proposed development is subject to payment of a contribution to Council under Section
94 or Section 94A of the Environmental Planning and Assessment Act, to provide for the
increased demand on Council services as a result of the proposed development.
Alternatively, a Voluntary Planning Agreement (VPA) under Section 93F of the Act may be
reached between the proponent and Leichhardt Council. Such a VPA may include a range of
works not specified on any current Council works schedule. In addition, it may include an
agreement to offset the costs of the works proposed against contributions otherwise payable
under Section 94 or Section 94A of the Act.
The Proponent requests that should the project be approved, a condition be placed on that
consent requiring the Proponent either pay Section 94 or Section 94A Contributions to
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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Leichhardt Council, or to enter into a new VPA with Leichhardt Council in lieu of such
payments, to the agreement of both parties. It is anticipated that the existing VPA which was
prepared in respect of the rezoning of the site would be replaced by any VPA agreement
entered into with Council in respect of the development or any requirement for Section 94
payments.
In summary, the Proponent has abandoned the earlier commitment to the provision of
community benefits and now seeks to offset any benefit against s.94 contributions.
It should be noted that no approach has been made to Council to renegotiate the VPA to
address any additional community benefits that might flow from the PPR.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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7 Conclusion
Despite the amendments to the proposal as outlined in the PPR, the proposed
redevelopment of the Balmain Leagues Club Precinct will result in an unacceptable change
to the urban form for the locality.
The proponent has not provided adequate justification for the building height and scale in the
context of the locality. The proposal ignores the local context and the constraints of the site.
What is currently a “small village” in an already constrained environment, particularly from a
traffic and transport perspective, will attempt to become a more significant centre adding to
traffic and transport congestion.
The constraints are not only unacceptable in terms of the consequent amenity outcomes;
they have the potential to significantly affect the viability of the "centre".
The planning framework and shortcomings of the development verify that a smaller scale
development is the most suitable outcome for the site.
This is an overdevelopment of the site. The site simply cannot accommodate such an
intensive form of development without adverse effects. A development with a reduced scale
could, with greatly reduced impacts, achieve:
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Increased housing supply for the LGA.
Increased employment.
An attractive gateway to Rozelle.
This submission demonstrates that:
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The proposal, as amended, continues to fail in terms of its urban design and
architectural merit and would result in poor amenity for future residents and users of
the retail area.
The development would have significant impact on surrounding residential streets and
the future trading of the existing retail shopping strip characteristics of Rozelle.
The proposal will result in unacceptable impacts on the surrounding traffic network,
including Victoria Road.
The proposal provides no justification for putting aside the well considered planning
outcomes that Rozelle should remain a "small village". In contrast, the provision of a
larger centre cannot be supported under the current State and Regional strategies for
the locality.
The development of the site requires careful consideration as to how the combination of land
uses will operate in harmony to deliver quality outcomes for the community and future
occupants as mandated when Council agreed to rezone the site for redevelopment in 2008.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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Council has now resolved to back zone the site to reflect the nature of the surrounding “High
Street” centre. The proposed “back zoning” provides Council with the opportunity to
undertake a fresh round of traffic, retail and social impact studies to determine an
appropriate future zoning and suite of development controls. Council seeks the support of
the Department of Planning and Infrastructure and the Planning Assessment Commission in
pursuing this line of action.
Balmain Leagues Club Precinct – PPR: Leichhardt Council’s Submission
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appendix a
photomontages
Photomontage No.1: View from Moodie Street, cnr of Waterloo Street, Rozelle
Photomontage No.2: View from cnr of Hamilton & Merton Streets, Rozelle
Photomontage No.3: View from Victoria Road, near Terry Street
Photomontage No.4: View from cnr of Darling and Denison Streets, Rozelle
Photomontage No.5: View from Henley Marine Drive
Photomontage No.6: View from Henley Marine Drive (cropped and zoomed)